Budget 2015: Expanded the Scope of 55(2) Tax Avoidance of Corporate Capital Gains (Section 55) The Income Tax Act contains an anti-avoidance rule that generally taxes as capital gains certain otherwise tax-deductible inter-corporate dividends. This rule typically applies where a corporation that is about to dispose of shares of another corporation receives from that other corporation tax-deductible […]
Income Tax Folio S3-F2-C1, Capital Dividends Series 3: Property, Investments and Savings Plans Folio 2: Dividends Chapter 1: Capital Dividends Summary This Chapter discusses capital dividends and the capital dividend account (CDA). The CDA keeps track of various tax-freesurpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the
Income Tax Folio S4-F3-C1, Price Adjustment Clauses Series 4: Businesses Folio 3: General Principles of Business Income Calculation Chapter 1: Price Adjustment Clauses Summary A price adjustment clause is typically incorporated into an agreement entered into by non-arm’s-length persons to provide for an adjustment to the transaction price in the event that a third-party such as
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February 15, 2008 In This Issue Safe Income Calculation – Treatment of Non-Deductible Expenses The Income Tax Technical News is produced by the Legislative Policy and Regulatory Affairs Branch. It is provided for information purposes only and does not replace the law. If you have any comments or suggestions about the matters discussed in this publication, please
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Income earned or realized – the Kruco case No. 33 September 16, 2005 In This Issue Income Earned or Realized – The Kruco Case Permanent Establishment – The Dudney Case Update The Income Tax Technical News is produced by the Policy and Planning Branch. It is provided for information purposes only and does not replace the law. If you have any
Income Earned or Realized – The Kruco Case Subsection 55(2) of the Income Tax Act (the “Act”) is an anti-avoidance provision directed against arrangements designed to use the inter-corporate dividend exemption to reduce a capital gain on the sale of a share. Subsection 55(2) will generally apply where the purpose of the dividend (or the result in the case
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